Subject: Comments on "S7-08-20”.
From: Charles Johnston
Affiliation:

Jul. 27, 2020

To whom it may concern: 


I am a small individual investor who manages his own investment portfolio. I have an issue with the rule change affecting the 13F filing requirements more specifically " rule change S7-08-20 which raises the AUM reporting requirement from $100 Million to $3.5 Billion. 


As investment funds and money managers already have a significant advantage over small investors like myself, the change that is currently proposed drastically reduces the public data that small investors like myself rely on to make and or to justify investment decisions. These changes only further the divide between the smaller investors who manage their own portfolios and the larger commercial investors who have direct access to the investment community. 


The current proposed rule change would drastically reduce the value of the 13F report to smaller investors. If there must be a change to the current rule, please consider a change that takes into consideration the needs of the smaller individual investor like myself. 


Regards, 


Chip Johnston